The larger territories and dependencies stuck to the deadline and have now taken important steps in the right direction for increasing transparency over company ownership.

The BVI implemented its Beneficial Ownership Secure Search (BOSS), an electronic search engine which contains information on company beneficial ownership. The Cayman Islands will set up its General Registry by August 2017, and by September 2017 Turks and Caicos will be requiring beneficial ownership information to be provided as part of all company registration processes. In all three cases, the information in the databases will only be exchanged with ‘competent authorities’ – government agencies and persons that have been given legal authority and power – in the host jurisdictions and in the UK.

The below table captures the progress made across a selection of OTs and CDs, as well as the UK itself. At present, there is no clear information differentiating whether the jurisdictions have implemented central registers or similarly effective systems. We will need to consider the results of the effectiveness reviews before we can assess the strength of either system.

But the process of developing timelines is simply a means to an end. Whether timelines are set, met or ignored entirely, what matters most is that we end up with a system robust enough to curb money laundering through these jurisdictions. In the 2016 Panama Papers leak, which exposed 11.5 million documents from company service provider Mossack Fonseca, over half of the 200,000+ companies were registered in the BVI alone. In the wake of the leak UK investigations are ongoing, but we know that nine potential professional enablers of crime have been identified; 43 high net worth individuals have been placed under special review, and; 26 offshore companies have been identified as suspicious.

So when it comes to considering the effectiveness of central registers in highlighting suspicious activity and preventing corruption, the real proof of the pudding will be in the eating. There will be two government reviews – in December 2017 and January 2019 – which will consider the effectiveness of these new systems. The Financial Action Task Force’s (FATF) Recommendation 33 states that maintaining comprehensive statistics is essential to assessing whether a country’s anti-money laundering system is effective. It is crucial that the findings of these reviews are published in full, so that there can be proper scrutiny over the capabilities of these registers to crack down on illicit activity.

What now?

The National Crime Agency should adhere to FATF recommendations and publish anti-money laundering statistics. This includes data on the number of queries from UK law enforcement into the central registers, as well as the number of responses received and the number of convictions deriving from investigations utilising information held in these central systems. When statistics and data around anti-money laundering are properly published, we will have a far better understanding of how effective these systems are.

Most importantly, however, to be credible in the fight against corruption, the gold standard ofpublic beneficial ownership registers should be the end goal for all OTs and CDs. Setting up central registers was a big step on the journey to transparency, but it must not be seen as a resting point. Timelines should be set and published for a transition to full transparency and accessibility of that beneficial ownership information.